Products can be imported into Iran from any number of countries, and by many different means, Clifford added. "There are a lot of Iranians in Dubai," he said. "They might buy locally from here one or two pieces and take it to Iran."
In response to questions about the IHPCRC's claim that it is using Opteron processors in the supercomputer, AMD officials issued the following written statement: "AMD has never authorized any shipments of AMD products to Iran or any other embargoed country, either directly or indirectly. AMD fully complies with all United States export control laws, and all authorized distributors of AMD products have contractually committed to AMD that they will do the same with respect to their sales and shipments of AMD products."
The statement added that any shipments of products to Iran by distributors "would be a breach of the specific provisions of their contracts with AMD."
The chip maker has increasing ties to the UAE. AMD last month announced that it had received $622 million in funding from a unit of Mubadala Development Co., an investment firm that is based in the UAE's capital of Abu Dhabi and owned by the Abu Dhabi government. Abu Dhabi is the largest of the seven emirates that make up the UAE, and its ruler – Sheikh Khalifa bin Zayed Al Nahyan – is also the UAE's president.
Legal experts said U.S. law requires companies with distributors in other countries to ensure that they also adhere to the trade sanctions against Iran, which is categorized as a terrorist country by the U.S. government. Companies that re-export U.S products are also prohibited from shipping them to Iran.
Nonetheless, Iranian officials have long boasted that the U.S. trade sanctions have had little impact on their nation's ability to acquire products that it needs from other countries.
Michael Izady, an adjunct professor of Middle Eastern and Western history at Pace University in New York, said via e-mail that "much of what Iran gets in computer parts and advanced devices are brought in – licitly or illicitly – from the UAE."
Izady said that Iran is producing as many computers as it does automobiles – about 1.6 million per year – and that the computer and Internet industry is "ubiquitous" in that country. "Iran is advancing its computer and Internet knowledge and expertise much faster than its nuclear program," he wrote.
"The fact there is stuff going into Iran is certainly well known to U.S. regulators," said Christopher Wall, an international trade attorney in the Washington office of Pillsbury Winthrop Shaw Pittman LLP. He added that the UAE has been a country of interest to a U.S. government program designed to stop shipments from foreign countries to Iran.
Although U.S. export law applies to foreign parties that are re-exporting U.S. products, a lot of that occurs without a license, according to Wall. In such cases, many of the foreign entities either don't follow the law or don't know its requirements, he said. Moreover, products may change hands many times before they get to their ultimate destinations.
"It's very difficult to enforce – extremely difficult to enforce," Wall said. That's why the sanctions against trade with Iran "are, in some cases, not very effective, because the rules are very easy to get around," he explained.
David Ivey, an attorney who specializes in international trade at Baker & Hostetler LLP in Houston, said that whatever the product is, exporters have to be sure it can legitimately be sold to other countries. AMD likely will have to do some due diligence to see if it can determine how its processors apparently ended up in Iran, Ivey said, "because the U.S. government may come and ask them that question."